Re: RIN 3245-AG24: Small Business Mentor Protégé Program; Small Business Size Regulations; Government Contracting Programs; 8(a) Business Development/Small Disadvantaged Business Status Determinations; HUBZone Program; Women-Owned Small Business Federal Contract Program; Rules of Procedure Governing Cases Before the Office of Hearings and Appeals

Dear Ms. Fernandez,

On behalf of our coalition of 4.7 million women business owners and 78 organizations, Women Impacting Public Policy (WIPP) is pleased to submit comments on the Small Business Administration (SBA) Proposed Rule (“rule”) regarding the Small Business Mentor-Protégé Program (MPP), issued February 5, 2015. As a leading advocate for women entrepreneurs engaged in or considering entering the federal marketplace, we appreciate the effort by the SBA to create a small business MPP available to women-owned small businesses (WOSBs).

The mentor-protégé relationship for government contractors is a valuable tool in bringing innovative and new companies into the federal marketplace. The benefits of this program are visible in many of the already existing MPPs. A statutory program at SBA open to WOSBs nonetheless has been a goal of WIPP, as documented in hearings and testimony throughout the legislative history. WIPP is excited to see this effort come to fruition.

Both the Small Business Jobs Act of 2010 (P.L 111-240) and the FY13 National Defense Authorization Act (112-239) addressed the issue of creating or expanding a mentor-protégé program similar to the 8(a) Business Development Program. The former addressed MPP in disadvantaged groups, including WOSBs, while the FY13 NDAA created a small business MPP. In the proposed rule, SBA proposes to create one new program in response to both pieces of legislation.

WIPP supports the decision of SBA to consolidate what would be four additional MPPs into one new program. In WIPP’s ChallengeHER and Give Me 5 programming, a constant refrain is the complexity of small business contracting programs. WIPP supports SBA’s election to keep the government-wide MPP solution simple. It is important, however, that the reasoning behind the legislation – in WIPP’s case the expansion to support development of WOSBs through mentorship – not be diluted by the unification of programs. WIPP asks that final rules address how resources specifically for WOSBs seeking to use the MPP will be dedicated.

In the proposed rule, the SBA also asks for comments on the future of other agency MPPs (with the exception of the MPP at the Department of Defense, which has its own statutory establishment and requirements). WIPP understands SBA’s contention that the need for these programs will likely diminish after SBA’s government-wide MPP is functioning. WIPP encourages SBA to learn from the successes and challenges of these programs.

For example, later in the proposed rule, SBA proposes that there be “open and closed” periods, should application numbers become unwieldy. Given that SBA will be overseeing the only statutorily supported MPP outside the Department of Defense, WIPP believes that the application process should be available without interruption. Occasional closures would be contrary to the government’s “no-wrong door” policy for small businesses and were a limiting factor in the success of the MPP at the Department of Veteran’s Affairs.

Women business owners have waited for five years for these regulations to open the doors to a more effective mentor-protégé program. WIPP advocated for this change and looks forward to a successful implementation based on the consensus of stakeholders.